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LAST UPDATED: MAY 27 2019
As a user of the Services you have certain rights, as you can read below. In particular, the choice to opt out of receiving any personalized content that may become available through some of the Services.
B. If you are a Customer
- Information we Collect About Customers
- How we Use Customer Information?
- Sharing Customer Information
- Your Choices
C. If you are an End User
- Information we Collect About End Users
- How We Collect End User Information
- Sharing or Disclosing User Information
- Users’ Choices
- Information Security
- Data Retention
- Cross-Border Data Transmission
- Children’s Privacy
- Comments and Questions
B. If YOU ARE A CUSTOMER:
If you are a Customer of the Services, in addition to the User Information we collect, we may collect Personal Information that you are required to submit to us when you open an account with us, for purposes of engaging with us in a business relationship or to otherwise integrate our Services into your own sites, products, software and services. In which case, our data collection practices will be as follows:
1. Information we collect about Customers
in addition to information we may collect about End Users, (as detailed below), if you are a Customer and you choose to open an account with us, you will be asked to submit certain Personally Identifiable Information, such as first and last name, email address of the entity on which behalf you are engaging with, a password for accessing your account and billing information. We will also ask you to fill out a form in which you will provide your organization’s billing address, URL and some financial information. We will also collect other Information that Customers choose to provide to us, such as the contents of a message that a Customer submits through our Website (collectively “Customer Information”).
2. HOW WE USE CUSTOMER INFORMATION?
We use Customer information in order to (i) render our Services and contact Customers that express their will to communicate with us and/or engage with the Services; (ii) communicate with Customers and respond to any inquiry or any other form of communications from Customers; and (iii) providing Customers with newsletters, promotions, updates, and other information Customer may find useful, including via email;
3. SHARING CUSTOMER INFORMATION.
We may disclose or share Customer Information to a current or future (i) affiliate, parent companies and/or subsidiaries that help us with facilitating the Services or operating the Website; (ii) services providers, agents, contractors, vendors and any other individual or entity which requires access to Customer Information in order to perform their functions; (iii) other Customers, to the extent required to render the Services and consented by Customer.
4. YOUR CHOICES.
As a Customer of us, you have certain rights concerning your Customer Information, including: edit, correct, verify, update or delete your Customer Information. If you wish to exercise any of those rights, you may do so by contacting us directly at: email@example.com In addition, any email communication we send to you, will include an opt-out / unsubscribe option that you can directly exercise via the email communication. Please note that if you choose to unsubscribe from email communication, we may still hold your account information and Customer Information and may contact you for updates regarding your use if the Services or any other relevant account information.
C. If YOU ARE AN END USER:
If you are an End User of the Services, the following data privacy practices are relevant for you:
1. INFORMATION WE COLLECT ABOUT END USERS
When you visit the Site or access, interact or engage with any of the Platforms, we may collect some information about such use as dependence of the type of Platform (and respective technology) with which you interact. Such information generally includes the following, and may be attributed to our Platform or Service ID that we generate for each type of Platform or to a general user ID that we generate for each user on the system and is a completely random identifier: device information (such as type, operating system type, version and language), your user agent, that includes the browser type, version and language from which you access the Platform or consume the Services, the domain or URL of the website you browse in which the Platform is integrated and the Services are displayed or served [please advise if you take full URL even if the site is served over https]. We may also collect the IP address of the device that accessed to the Services for purposes extracting the End User geographic location. In which case the IP address is not retained. User Information and Customer Information will be jointly referred to as “Information”.
2. HOW WE COLLECT END USER INFORMATION?
3. HOW DO WE USE USER INFORMATION?
Please note that we use User Information for purposes of operating the Platforms, providing the Services and constantly improve them. That includes the following uses: (i) Operating and further developing and improving the Services; (ii) For counting and tracking purposes when the Platform involves ad serving and campaign management; (iii) Validation of users as humans; (iv) Where you provided us with your email address, for example if you contact with us for an inquiry or request, we will use your contact details and inquiry content to process it and respond and other communications with you; (v) Identify or authenticate your access and use of your account (in case of a Customer Information). (vi) Personalized Content and Advertising. When a User interacts with our widget, we may facilitate the transmission of certain device information and End User information. This information includes user agent, IP address, Cookie ID and additional parameters about the End User’s consent. We do not retain this information, however enable by it the serving of personalized content. This information is never used to personally identify any individual and is handled with compliance to applicable laws, as we strictly require our advertising partners. (vii) Retargeting. Some of our third-party services may collect non-identifiable information about your interaction with the Platforms. Such information may be used by such third parties for serving and displaying ads and offers (“Ad/s”) when you browse other websites across the web (“Retargeting”). You will have the choice to opt-out at any time of such type of advertising, directly from the Ad when you encounter it, from the ad setting of the providing third party services. (viii) For any legally permissible purpose in our sole discretion or law enforcement requirement;
4. SHARING OR DISCLOSING USER INFORMATION
5. USER CHOICES.
6. INFORMATION SECURITY
We, and third party services/affiliate entities implement data security systems and procedures to secure the information transmitted, processed and stored in our computer servers and systems. For example, the Site is encrypted by using SSL and so as any other information at transport, we periodically review our information and data collection practices to ensure constant monitoring, we use third party processing and serving services that implement various information security standards and certifications (at rest and transmission), and we monitor and filter access to data when it comes to personnel in our organization. Such systems and procedures reduce the risk of security breaches, but they do not provide absolute security, as there is no such thing when it comes to the world-wide network. Therefore, we cannot guarantee that the Services and our servers are immune to unauthorized access to the information stored therein and to other information security risks. If you have any questions about our security and safeguards efforts, you can contact us at: privacy@iito,me
7. DATA RETENTION
Unless we are instructed otherwise by applicable laws, we retain Information we collect for as long as needed to provide the Services, operate them, monitor them, and to comply with our legal obligations, resolve disputes and enforce our agreements.
8. CROSS-BORDER DATA TRANSMISSION
9. CHILDREN’S PRIVACY
The Services are not designed to attract children under the age of 21. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 21. If we learn that we have collected Personal Information from a child under 21, we will use commercially reasonable efforts to delete that information as quickly as possible. If you believe that we might have any such information, please contact us in accordance to the contact information set forth below.
10. COMMENTS AND QUESTIONS
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